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Who wins?

Arm under the pillow vs Right side

Right side wins 76% to 24%. 15 more put them in the same row. From Sleep Positions Tier List. Pick a side.

SoggyLlama on Arm under the pillow: the cool pillow side keeps it worth it
wet_taco_8734 on Right side: no difference, sleep how you want

Sleep Positions Tier List: the full ranking

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